DECISION AND ORDER INTRODUCTION Plaintiffs the Diocese of Rochester and the Diocese of Buffalo, N.Y. (collectively “Plaintiffs”) seek a preliminary injunction against defendants U.S. Small Business Administration (“SBA”) and Jovita Corranza (the “Administrator”) (collectively “Defendants”) related to Defendants’ establishment of criteria for participation in the Paycheck Protection Program (the “PPP”). (Dkt. 17). Plaintiffs assert that Defendants violated the Administrative Procedure Act, 5 U.S.C. §§701 et seq. (the “APA”) and Section 525(a) of the Bankruptcy Code, 11 U.S.C. §525(a), by determining that debtors in bankruptcy are not eligible for loans issued in connection with the PPP. Plaintiffs ask the Court to enjoin Defendants from (1) denying Plaintiffs a PPP loan or otherwise interfering with the processing of their applications due to their status as chapter 11 bankruptcy debtors and (2) “disbursing from the PPP an amount equal to the total amount requested in [Plaintiffs'] combined loan applications, or $2,836,096.” (Dkt. 17 at 1). Following oral argument on Plaintiffs’ amended motion for a preliminary injunction, the Court issued a Notice pursuant to Federal Rule of Civil Procedure 56(f)(3) advising the parties that it intended to consider granting summary judgment with respect to the following issues: (1) whether the SBA exceeded its statutory authority under the Coronavirus Aid, Relief, and Economic Security Act (“CARES”), Pub. L. No. 116-136, 134 Stat. 281 (2020), by excluding debtors in bankruptcy from participation in the PPP; and (2) whether the SBA violated 11 U.S.C. §525(a) by excluding debtors in bankruptcy from participation in the PPP. (Dkt. 35) For the reasons set forth below, the Court concludes that those legal questions must be resolved in favor of Defendants — the SBA did not exceed its statutory authority under the CARES Act nor did it violate 11 U.S.C. §525(a) when it adopted the bankruptcy exclusion to the PPP. As a result, the Court grants summary judgment to Defendants to the extent Plaintiffs seek a declaratory judgment otherwise. The Court further denies Plaintiffs’ amended motion for a preliminary injunction because they have not demonstrated a likelihood of success as to the remaining claims in this matter nor have they established irreparable harm. FACTUAL BACKGROUND Plaintiffs are Roman Catholic dioceses and not-for-profit religious corporations under New York law. (Dkt. 10 at
